As has been widely reported, LIBOR is expected to be phased out by the end of 2021. With no readily available replacement, it has been left to market participants to develop and transition to alternative reference rates and to determine a transition plan.

A Department of Justice internal memo dated January 10, 2018 reflects a significant policy change regarding the DOJ’s election to dismiss certain qui tam lawsuits in which the government declines to intervene. The Memo (a copy of which can be found here) notes that the number of qui tam actions...

A June 2017 decision by a federal district court in the District of Columbia determined that a reference laboratory cannot rely on the ordering physician’s determination to establish medical necessity for testing paid for under Medicare, Medicaid, or other federal health care programs.[1] In...

On December 19, 2017, the U.S. Department of Justice (“DOJ”) announced settlements with two separate physician groups, one in Texas and one in Pennsylvania relating to allegations that the groups received illegal remuneration in exchange for patient referrals to hospitals owned by the...

Financial institutions offering purchase money auto and personal property loans received an unwanted holiday surprise from the Department of Defense (the "DoD" or the "Department"), with the December 14, 2017 "Interpretative Rule" (the "2017 Interpretative Rule") to the Military Lending Act (the...

A December 28, 2017 CMS memo to state surveyors clarifies CMS’ position as it relates to texting of orders by physicians or other health care providers as well as utilizing text messaging as a means of communication among the healthcare team.[1] In its memo, CMS holds that the practice of...